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          Code of Conduct

          KEYENCE Code of Behavior

          KEYENCE has built a system that requires all employees to regularly conform to our Corporate Policy and Business Guidelines. The KEYENCE Corporate Policy defines our employee code of behavior, in order to maintain an organization that reduces the probability of abuse, harassment, or any other wrong doing. By proactively applying these standards to our everyday operations, we continue to ensure thorough compliance of ethical behavior.

          This Code sets forth minimum requirements of KEYENCE employees that are consistent with KEYENCE’s values and are applicable to all KEYENCE employees, our suppliers, their respective affiliates, and subsidiaries globally. KEYENCE shall at all times operate in full compliance with all applicable laws, rules and regulations (collectively “Laws”). These include, but are not limited to:

          • 1)RESPECTING THE HUMAN RIGHTS OF WORKERS (LABOR RELATIONS)

            • a)Human Rights: KEYENCE is committed to complying with all applicable labor Laws and proactively raising awareness to these Laws. It is our expectation that employees should have an ethical working environment, free from discrimination and harassment. KEYENCE shall treat workers with dignity and respect and shall not engage in or permit corporal punishment or threatened or actual violence.

            • b)Child Labor: KEYENCE shall only employ or engage workers who meet the applicable minimum legal age requirements. KEYENCE will not use child labor. KEYENCE will not employ any person under the age of 15 or below the legal minimum age, if higher.

            • c)Forced Labor: KEYENCE shall not use or engage in any indentured or forced labor, slavery or servitude, human trafficking or compulsory labor.

            • d)Prohibition of Discrimination and Harassment: KEYENCE shall not engage in any discrimination or harassment, whether based on gender, race, color, religion, ethnicity, social background, age, sexual orientation, national origin, disability, political conviction or any additional legally protected characteristics.

            • e)Wages and Working Hours: KEYENCE shall pay all workers at least the minimum wage required by applicable laws and regulations and provide all legally mandated benefits. In addition, workers shall be compensated for overtime hours at the rate required by applicable laws and regulations.

          • 2)BUSINESS ETHICS

            • a)Conflict of Interest: A conflict of interest occurs when personal interests or activities influence, or appear to influence, the ability to act in the best interests of KEYENCE. Suppliers and employees must disclose any family members (or those personally close to them) who work for KEYENCE, a KEYENCE supplier, KEYENCE customer or KEYENCE competitor. Any situation that even has the appearance of a conflict of interest should be disclosed to KEYENCE.

            • b)Gifts, and Entertainment: When doing business with or conducting business on behalf of KEYENCE, employees shall refrain from offering gifts or entertainment to and from KEYENCE customers.

            • c)Anti-Corruption, Bribery, and Kickbacks: KEYENCE is committed to maintaining an ethical business environment and conducting business in compliance with the anti-corruption laws in all countries KEYENCE operates, including, but not limited to, the U.S. Foreign Corrupt Practices Act, and all other applicable anti-corruption laws. KEYENCE affirms, it shall not directly or indirectly solicit, receive or offer any form of bribe, kickback, or other corrupt payment, to or from any person or organization, including but not limited to government agencies or officials, companies or Personnel of those companies.

            • d)Fair Trade: KEYENCE shall not engage in collusive bidding, price fixing, price discrimination or other unfair trade practices in violation of antitrust laws.

            • e)Intellectual Property and Confidentiality: KEYENCE is committed to protecting and respecting confidential information. KEYENCE will ensure that any confidential business information, trade secrets or other intellectual property gained by virtue of business actives with their customers is held in strict confidence and will not be improperly used or disclosed to third parties.

            • f)Data privacy and security: KEYENCE will comply with all local laws concerning data security and privacy, and will protect and safeguard data provided to KEYENCE, which may include private and sensitive personal information. Any transfer or sharing of data must be done in a manner that protects such information from inadvertent or unauthorized disclosure and any disclosure must be in compliance with local laws.

          • 3)ENVIRONMENT, HEALTH AND SAFETY

            • a)Environmental Safety: KEYENCE complies with environment laws, regulations, and other requirements, and work on environmental conservation by establishing voluntary management standards. In order to reduce our environmental burden, we have established and maintain an environmental management system to continuously improve and promote the prevention of environmental pollution. For more information on our environmental policies, please visit our website here: https://www.keyence.com/about-us/sustainability/burden-product.jsp.

            • b)Occupational Safety: KEYENCE shall commit to the safety and health of their employees, and shall ensure that required training of personnel has been completed prior to initiating any work activity. KEYENCE has a written safety and health program for addressing and controlling worker exposure to potential safety hazards in conformance with all applicable standards and/or regulations and by utilizing suitable means, e.g., administrative controls, preventative maintenance, training, work procedures, and appropriate personal protective equipment.

          • 4)SUPPLY CHAIN

            • a)Procurement: In selecting suppliers, KEYENCE seeks to do business with reputable business partners who are committed to ethical standards and business practices compatible with those of KEYENCE. In order to ensure a workplace that takes human rights into consideration, we have established procurement guidelines for our supply chain, and request that our suppliers follow these: https://www.keyence.com/about-us/corporate/procurement_guideline.jsp. In addition, as part of our basic business agreement, we request that these suppliers make efforts to reduce their environmental impact and prevent environmental pollution to protect the environment.

            • b)Conflict Minerals: Conflict minerals originating in the Democratic Republic of the Congo (DRC) or an adjoining country (hereinafter called “the covered countries”) have become a source of funding for armed groups, leading to human rights violations and environmental destruction while threatening to promote further conflict. The four minerals in question (tin, tantalum, tungsten, and gold) are widely used in electric and electronic products. It is KEYENCE policy to refrain from the purchase of any parts, components, and materials that are recognized to contain conflict minerals. Furthermore, KEYENCE has no intention to benefit or finance the armed groups responsible for human-rights violations in the covered countries. KEYENCE is engaging in efforts to eliminate conflict minerals while cooperating with suppliers, such as investigating supply chains using tools provided by the Responsible Minerals Initiative (RMI) (formerly CFSI), an organization that promotes the responsible procurement of minerals.

          • 5)GOVERNANCE

            • a)Review: To maintain an organization that is less prone to fraud and harassment, we have a system where all employees review the Corporate policy and Business Guideline that form our code of conduct. In addition, by actively using this code of behavior as judgment criteria in our daily business, we are working to ensure thorough compliance and improve compliance awareness.

            • b)Internal Audit Team: An appointed audit team has been formed to conduct internal audits. The audit team conducts internal audit focusing on the appropriateness and effectiveness of business operations at KEYENCE. https://www.keyence.com/about-us/sustainability/governance.jsp